From:
"David Ailor" <dailor@accci.org>
Sent:
Fri, 19 Aug 2022 15:19:16 
To:
<daly.owen@epa.gov>; "'French; Chuck'" <French.Chuck@epa.gov>; <fruh.steve@epa.gov>; "'Jones; DonnaLee'" <Jones.Donnalee@epa.gov>; <lin.walter@epa.gov>; "'Mcginn; Kevin'" <mcginn.kevin@epa.gov>; "'GABRIELLE RAYMOND'" <graymond@rti.org>; "'Shappley; Ned'" <Shappley.Ned@epa.gov>
Subject:
RE: DRAFT LISTS OF COETF AND EPA "DO-OUTS" FROM YESTERDAY'S CALL ON 114 TESTING
Hello again, Donna Lee.  
 
I'm following up on two of the three COETF "do-outs" from our Tuesday, August 9 call to discuss the Coke Ovens ICR.  The two do-outs are (1) "Provide close-up images of battery bench showing safety hazards  -  tight spaces, moving equipment, etc." and (2) "Provide OSHA reports on previous injuries/fatalities."  What we are providing on each of these is discussed below:
 
1. Provide close-up images of battery bench showing safety hazards  -  tight spaces, moving equipment, etc.  During the August 9 call, EPA requested close-up images of the battery bench showing the potential safety hazards, including narrow spaces and areas where there is moving equipment on the bench.  Two example photos are included in the attached ".pdf" file (see "COETF Example Bench Photos.pdf").
 
2. Provide OSHA reports on previous injuries/fatalities.  EPA also requested that the COETF provide examples of OSHA incident reports for accidents on coke battery benches.  A ".pdf" file listing several examples is attached (see "Accident Report Detail _ Occupational Safety and Health Administration (SIC 3312).pdf").
 
Lastly, two of EPA's "do-outs" from the August 9 call are a "Response to COETF's letter requesting changes to the ICR schedule (expedited response requested)" and a "Response to COETF's letter requesting changes to the ICR scope."  Can you please advise when EPA will be providing responses to these time-sensitive requests?  The COETF would greatly appreciate knowing as soon as possible if EPA is making changes to the ICR scope and providing the requested extensions of time.
 
Thanks.  And, please contact me if you have any questions.  DCA
 
David C. Ailor, P.E.
President
American Coke and Coal Chemicals Institute
25 Massachusetts Avenue, N.W.Suite 800Washington, D.C. 20001
Phone: 703-795-3541
eFax.: 866-422-7794
dailor@accci.org 
www.accci.org 

<<COETF Example Bench Photos.pdf>>
<<Accident Report Detail _ Occupational Safety and Health Administration (SIC 3312).pdf>>

 
From: David Ailor <dailor@accci.org> 
Sent: Wednesday, August 10, 2022 4:59 PM
To: daly.owen@epa.gov; 'French, Chuck' <French.Chuck@epa.gov>; fruh.steve@epa.gov; 'Jones, DonnaLee' <Jones.Donnalee@epa.gov>; lin.walter@epa.gov; 'Mcginn, Kevin' <mcginn.kevin@epa.gov>; 'GABRIELLE RAYMOND' <graymond@rti.org>; 'Shappley, Ned' <Shappley.Ned@epa.gov>
Subject: DRAFT LISTS OF COETF AND EPA "DO-OUTS" FROM YESTERDAY'S CALL ON 114 TESTING
 
Donna Lee et al.:
 
Thanks again for making the time to meet with the Coke Oven Environmental Task Force (COETF) yesterday to discuss 114 testing the Agency is requesting.  Below, as promised, are draft lists developed by the COETF inclusive of what we believe are the COETF and EPA "do-outs" from the call.  Please let us know ASAP of any errors/omissions you might identify.  Thanks, David Ailor
 
COETF Do-Outs:
 
1. Provide close-up images of battery bench showing safety hazards  -  tight spaces, moving equipment, etc.
2. Provide OSHA reports on previous injuries/fatalities
3. Follow-up on EPA request for information on composition/speciation of VOC from byproduct plant processes (LDAR program)
 
EPA Do-Outs:

1.	Response to COETF's letter requesting changes to the ICR schedule (expedited response requested)
2.	Response to COETF's letter requesting changes to the ICR scope 
3.	Provide list of ambient monitoring stations for which EPA already has data 4.	If any interior/fenceline fugitive monitoring remains in the ICR, confirm whether method can be limited to passive samplers and fenceline locations reduced to 1-2 upwind and 1 downwind
5.	Confirm whether EPA will accept USS SCOT plant stack test data in lieu of performing new testing
6.	Confirm whether EPA will accept DTE/EES COG sample data in lieu of performing new testing 
 
 
David C. Ailor, P.E.
President
American Coke and Coal Chemicals Institute
25 Massachusetts Avenue, N.W.
Suite 800
Washington, D.C. 20001
Phone: 703-795-3541
eFax.: 866-422-7794
dailor@accci.org
www.accci.org 


